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Citigroup Inc. v. Otto Candies, LLC, et al.

Paid petition · United States Court of Appeals for the Eleventh Circuit, No. 23-13152 · judgment May 8, 2025


Certiorari denied · January 12, 2026
Pre-decision estimate: 4% cert probability

Before the decision, roughly the 4.1% base rate. The model weighted this up for counsel who has won certiorari before, an Eleventh Circuit decision below, and a business petitioner, and down for a business respondent.

Question presented

In the Private Securities Litigation Reform Act (PSLRA), Congress barred plaintiffs from bringing claims under the Racketeer Influenced and Corrupt Organizations Act (RICO) based on conduct already covered by the federal securities laws. In particular, the PSLRA provides that “no person may rely upon any conduct that would have been actionable as fraud in the purchase or sale of securities” to establish a RICO violation. 18 U.S.C. § 1964(c). The question presented is whether the PSLRA bars a civil RICO claim based on conduct that is actionable as securities fraud by another potential plaintiff, even if the particular RICO plaintiff could not bring a securities-fraud claim. (I)

Counsel of record

For petitioner
Jeffrey B. Wall
Sullivan & Cromwell LLP

For respondent
Derek L. Shaffer
Quinn Emanuel Urquhart & Sullivan, LLP

Case

Conference history
Distributed for 1 conference

Amicus briefs
2 cert-stage

Proceedings

  1. Jan 12 2026
    Petition DENIED.
  2. Dec 23 2025
    DISTRIBUTED for Conference of 1/9/2026.
  3. Dec 19 2025
    Reply of petitioner Citigroup Inc. filed. (Distributed)
  4. Dec 03 2025
    Brief of respondents Otto Candies, LLC, et al. in opposition filed.
  5. Nov 03 2025
    Brief amicus curiae of Washington Legal Foundation filed.
  6. Nov 03 2025
    Brief amici curiae of Securities Industry, et al. filed.
  7. Oct 10 2025
    Motion to extend the time to file a response is granted and the time is extended to and including December 3, 2025.
  8. Oct 08 2025
    Motion to extend the time to file a response from November 3, 2025 to December 3, 2025, submitted to The Clerk.
  9. Sep 30 2025
    Petition for a writ of certiorari filed. (Response due November 3, 2025)